I am writing to request an exemption from 14 CFR § 121.311(b) to the extent 

required for KAYLEE ADDIE to be able to use an FAA Approved Child Restraint 

System even though she exceeds the weight limits for the CRS. In addition, if my 

petition is granted, I request that any air carrier or commercial operator operating 

under part 121 while KAYLEE ADDIE is aboard its aircraft is granted an 

exemption from 14 CFR § 121.311(b)(2)(iii)(B) to the extent necessary to allow 

KAYLEE ADDIE to exceed the specified weight limit for an FAA-approved child 

restraint system during use of that child restraint system aboard an aircraft.

I believe the pertinent section from 14 CFR part 121 from which we seek relief is 

Section 121.311 Seats, safety belts, and shoulder harnesses.

KAYLEE ADDIE is 16 year’s old, weighs 120 pounds, and is 63 inches tall.

KAYLEE ADDIE’s physical condition is as follows: CP with chronic restrictive lung 

disease/ spastic quadriplegia. As a result of her physical condition, she needs the 

support and security provided by an FAA Approved Child Restraint, but because of 

her weight is incapable of compliance with the regulation. I am also submitting 

the following contact information: Mackenzie Sipiora, Make-A-Wish AK & 

WA, 811 First Ave Suite 520 Seattle WA 98104, mackenzie@akwa.wish.org. 

I understand that the regulation is written to create a high level of safety for each 

individual passenger by ensuring that they are securely restrained in their seats 

during all phases of flight. The regulation also ensures that an individual does not 

cause harm to other passengers on the airplane by being thrown into them during 

turbulent or emergency conditions.

I propose that KAYLEE ADDIE be allowed to occupy an FAA Approved Child 

Restraint (CARES, manufactured by AmSafe, Inc.), even though she exceeds the 

manufacturer’s weight limits. This ensures a high level of safety for KAYLEE 

ADDIE and a high level of safety for the other passengers and crew on the airplane. 

In fact, in KAYLEE ADDIE’S case, safety is greatly enhanced by the extra support 

and security that the FAA Approved Restraint System will provide during the 

entire flight.

Enhancing safety for KAYLEE ADDIE is in the public interest. In addition, the 

public interest is also served by the fact that the use of this FAA Approved Child 
Restraint System allows him to use commercial air transportation. Without the 

support and security of the FAA Approved Child Restraint System, he would be 

unable to fly commercially.

I also believe that, with certain limitations established by the FAA in a grant to this 

petition, there can be an equivalent level of safety to that provided by the affected 

regulation. The CARES restraint has been certified by the manufacturer for use by 

children 22- 44 pounds. However, the components of the CARES restraint are the 

same as those used in restraints for adults on aircraft and would maintain their 

integrity if used by someone who weighed several hundred pounds.

I believe that the limit of 44 pounds was established because, with the additional 

weight of the child attached to the seatback, the seatback would move forward more 

quickly in an accident scenario and this might cause a higher HIC load for the 

person seated in the seat behind the passenger using the CARES restraint (because 

the seatback moving forward more quickly would mean that it would not be there to 

attenuate the energy from the impact of the person seated behind the person using 

the CARES restraint).

In order to achieve an equivalent level of safety as that provided by the affected 

regulation, I propose I propose that all operations under this exemption be 

conducted with at least one of KAYLEE ADDIE’s parents accompanying her: 

Michelle Addie. In addition, I propose that KAYLEE ADDIE’s parent must carry a 

copy of this exemption.

I also request that the processing of this petition not be delayed for publication and 

comment in the Federal Register. We want to travel OCTOBER 30TH -

NOVEMBER 3RD 2014, If you take the time to put this in the Federal Register, it 

will delay the process and we may not be able to travel in this timeframe.

If it is necessary to put a summary in the Federal Register, I submit the following:

This is a request for an exemption from FAR 121.311 (b) to the extent required for a 

child to use an FAA Approved Child Restraint System on an aircraft, even though 

the child exceeds the weight limits for the CRS. Due to physical challenges, without 

the support and security of this FAA Approved Child Restraint System, this child 

would be unable to fly. We request that this child be allowed to occupy an FAA 

Approved Child Restraint (CARES, manufactured by AmSafe, Inc.), even though 

she exceeds the manufacturer’s weight limits of 44 pounds. In this case, the safety 
of this child is greatly enhanced by the extra support and security that the FAA 

Approved Restraint System will provide for him during the flight.

Thank you for your consideration of this request. 

Mackenzie Sipiora

Wish Coordinator

Make-A-Wish Alaska & WA